HACCP Becoming a Paper Exercise

[Marzena STC & QTC]

Just wanted to raise a topic that comes up frequently during audits.

Many HACCP studies start out as practical risk management tools, but over time they can become large documents that are updated for compliance purposes rather than actively used by production teams.

How do you keep HACCP relevant and meaningful on the factory floor? Do operators and supervisors genuinely understand the hazards and controls, or is the HACCP plan mainly used during audits?

Interested to hear how businesses bridge the gap between compliance and practical implementation.

 

[Shaun]

I agree with the premise of this question.

I think this is one of the biggest challenges with HACCP. Many HACCP studies do genuinely start out as practical risk management tools but then yes they can gradually evolve into large compliance documents that very few people actually use to manage food safety on a day-to-day basis. It gets looked at during the annual review and then if an auditor is on the site.

The result of which is problems within the HACCP itself because it becomes less about the study and more about ticking boxes.
A common example is vacuum packing, where the hazard analysis states that the process prevents microbiological growth. In reality, vacuum packing does not eliminate the potential for microbial growth; it changes the environment and therefore changes the hazard profile of the product. While it may support shelf-life extension by inhibiting many aerobic spoilage organisms, it can also increase the significance of hazards such as Clostridium botulinum if factors such as temperature control, shelf life and product characteristics are not properly managed. The result is often a HACCP study that documents the perceived benefit of the process while overlooking the hazards created by it.

I also see HACCP plans occasionally working backwards from the answer they want. The same microorganism can be given one severity score at the start of the process and a completely different severity score later in the study, despite nothing having happened that would change the consequence to the consumer if the hazard were present. Most controls reduce the likelihood of a hazard occurring, they do not change how severe the outcome would be if the hazard reached the consumer. This for me is the biggest indicator of when it has become a paper exercise, because when scoring is adjusted to support the desired classification of a process step, the hazard analysis is no longer an objective assessment of risk.

For me, one of the best indicators of whether HACCP remains relevant is whether people on the factory floor can explain why controls exist. If operators understand the hazards associated with their process, what could go wrong and what actions they need to take when controls fail, the HACCP study is actually adding value. I don't expect them to know every process, but knowing their process is a huge plus plus in my book.

The strongest HACCP systems I see are generally not the longest or most detailed. They are the ones where the hazard analysis accurately reflects the process, the controls are practical, and the people running the process understand the risks.

So to bridge the gap, I think we need to spend less time teaching people how to complete HACCP paperwork and comply with X, Y and Z requirements and more time teaching them how to think about hazards and risk. Even the BRCGS course is heavily compliance to HACCP and Standard requirements focused.
The best HACCP teams I encounter are not necessarily those with the most detailed studies, but those that challenge assumptions, ask what could go wrong and objectively assess the risks introduced by each process step.
We also need to encourage HACCP teams to be comfortable with following the evidence wherever it leads, rather than feeling pressured to reach a particular outcome. If a process introduces a hazard, that should be recognised. If a control only affects likelihood, that should be reflected in the scoring. The objective should be to understand and manage the real risks within the process, not to justify the process itself.
Finally, operators need to be brought into the conversation. HACCP is most effective when the outputs are translated into practical controls, training and day-to-day decision-making. If the people running the process understand the hazards and controls relevant to their role, the HACCP study becomes a living system rather than a document that is only reviewed during audits. So many HACCP teams lack a production operative (they may have the production manager, but not an operative that actually undertakes the process day in day out) and sites should really be thinking about that.

As you can see, this is a topic I can talk about all day!

 

[Marzena STC & QTC]

Thank you, Shaun. I couldn't agree more.

You've explained it really well and highlighted a challenge that I see frequently during audits. HACCP should be a practical tool used by the people managing the process, not just a document created to satisfy a standard or pass an audit.

I particularly agree with your point about operators understanding the controls relevant to their role. If people on the factory floor can explain what could go wrong, what controls are in place and what action to take when something isn't right, that demonstrates a much stronger food safety culture than simply maintaining a well-written HACCP study.
I also think there can sometimes be a tendency to overcomplicate HACCP, making it less accessible to those who use it day to day. Finding the right balance between compliance and practicality is often one of the biggest challenges.
Thank you for sharing your thoughts. It's clear this is a topic you're passionate about, and I suspect many people in the industry will relate to your comments.